Privacy Policy
Last updated: 24 September 2026
This policy describes how we process the personal data of users who visit this site and contact us, pursuant to Regulation (EU) 2016/679 (GDPR).
Data Controllers
This site is operated under joint controllership (art. 26 GDPR) by Cesare Bedin (VAT 05755090288) and Federico De Cillia (VAT IT13990330964), who jointly determine the purposes and means of the processing.
For any request regarding personal data, including exercising your rights, the single point of contact is: info@flylabs.ai. The joint controllers have set out their respective areas of responsibility in an arrangement; its essence is available on request.
No Data Protection Officer (DPO) has been appointed: the conditions of art. 37 GDPR do not apply (no large-scale systematic monitoring nor processing of special categories as a core activity).
Data we collect
Data you provide voluntarily: when you contact us through the form we collect the data you share (name, email, any company and the text of your request).
Navigation data: systems and servers automatically collect certain technical data (for example IP address, browser type, pages visited, date and time), necessary for the operation and security of the site.
Conversations with the assistant: if you open and use the chatbot, the text you enter is processed to provide you an answer (see the “Assistant” section).
Cookies and tracking tools: see the dedicated Cookie Policy.
Purposes and legal bases
Responding to requests sent via the form. Legal basis: performance of pre-contractual measures requested by the data subject (art. 6.1.b).
Answering your questions about our services through the chatbot. Legal basis: pre-contractual steps at your request (art. 6.1.b).
Ensuring operation, security and abuse prevention (for example anti-spam limits on the form). Legal basis: the Controller's legitimate interest.
Measuring site traffic and performance in aggregate. Legal basis: legitimate interest via cookieless tools (Vercel); Google Analytics is activated only with your prior consent (art. 6.1.a).
Complying with legal obligations, including tax and accounting ones. Legal basis: legal obligation (art. 6.1.c).
Whether providing data is required
In the contact form, name and email are required so we can reply to you: without them we cannot follow up on your request. The other fields are optional.
Recipients and processors
To deliver the service we rely on third-party providers acting as processors under art. 28 GDPR: Vercel Inc. (site hosting and cookieless Web Analytics/Speed Insights), Sanity (content management system), Resend (sending emails generated by the form), the assistant platform (GPT-trainer by Paladin Max, Inc., via gptchatbot.it, which uses a Google language model to generate answers) and, where activated, Google (Google Analytics 4).
Data is neither disclosed publicly nor sold to third parties for their own marketing purposes. An up-to-date list of processors is available on request.
Transfers outside the European Union
Some providers (for example Vercel, Resend and Google) may process data in the United States. In that case the transfer is based on appropriate safeguards: standard contractual clauses (SCC) and/or EU-US Data Privacy Framework certification. You can request a copy of the safeguards by writing to info@flylabs.ai.
Conversations with the assistant are stored in the United States by the platform provider (see the “Assistant” section), which does not currently publish the transfer mechanism it relies on: we are verifying it with the provider. In the meantime, please do not enter unnecessary personal data in the chat.
Assistant (chatbot)
The assistant runs on the GPT-trainer platform by Paladin Max, Inc. (United States), via gptchatbot.it, and activates only when you open it. The messages you write are processed to generate replies and stored on Amazon Web Services servers in Oregon (USA); to produce the reply, the text is sent to a Google language model (Gemini). GPT-trainer states that it does not use user content to train AI models. Conversations may constitute personal data: please do not enter special-category data (art. 9 GDPR), confidential data, or third parties' data. On request to info@flylabs.ai we delete your conversations.
Retention period
Form/request data not turned into a relationship: 24 months, then deleted automatically. Contractual, accounting and tax data: 10 years (art. 2220 of the Italian Civil Code and tax law). Hosting platform technical logs (Vercel): 30 days at most, currently 1 hour. Assistant conversations: on the provider's platform until we delete them; you can ask us to delete them at any time. Cookie choices: up to 6 months, after which consent is requested again. Cookie choice records (choice per category, banner version, language, date and time, browser and operating system family): 24 months from recording, so that we can demonstrate consent (art. 7(1) GDPR), then deleted automatically. The IP address, stored only in pseudonymised form (hash) to limit abuse of the form and of the record, is removed after 30 days.
Your rights
As a data subject you have the right to access your data, request its rectification or erasure, restrict its processing and obtain data portability, as well as to withdraw at any time any consent given (for example for analytics or the assistant).
Right to object: you can object at any time to processing based on our legitimate interest (site security, cookieless analytics) by writing to info@flylabs.ai.
You can exercise these rights by writing to info@flylabs.ai. You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it).
Automated decision-making
We do not carry out processing that produces automated decisions with legal or similarly significant effects under art. 22 GDPR. The assistant provides answers generated by a language model for informational and first-contact purposes, and does not make decisions about the user.
Cookies
The site uses strictly necessary cookies, always on. Analytics (Google Analytics) and the AI assistant run only with your consent. You can manage or withdraw your choices at any time from the Cookie Policy or the “Manage cookies” link in the footer.
Changes to this policy
We may update this policy over time. The current version is always published on this page, with the date of the latest update.
